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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.



(1) Royalties arising from a Contracting State, whose beneficial owner is a resident of the other Contracting State, shall be liable to taxation only in that other State.

(2) The term "royalties" as used in this Article means payments of any kind derived as a consideration for the use of, or the right to use, any copyright on literary, artistic or scientific work, including cinematographic films and the films, tapes or any other means of image or sound reproduction, any patent, trademark, design or model, plan, secret formula or process, or for the use or right to use industrial, commercial or scientific equipment, or for information relating to industrial, commercial or scientific experience. The term "royalties" likewise covers any amounts paid in respect for the use or the concession of using the names, images and other similar individual rights, as well as the remuneration pertaining to recordings of performances of artists and athletes broadcast by television channels or radio stations.

(3) The provisions of paragraph (1) of this Article shall not be applicable when the beneficial owner of the royalties, being a resident of a Contracting State, performs economic activities in the other Contracting State from which the royalties arise, maintaining a permanent establishment therein, while the rights or benefits for which the royalties are paid are effectively connected with the aforesaid permanent establishment. In such cases, the provisions of Article 7 of this Convention shall apply.

(4) Where, by reason of a special relationship between the payer and the beneficial owner of the royalties, or between both of them and some other person, the amount of the royalties, having due regard to the use, rights or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In such cases, the excess portion of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention.